The appeal concerned a decision about HMRC’s refusal of entrepreneurs’ relief on whether the shares were held for the required one year-period.

This is a further round in the proceedings, following a previous decision by First Tier Tribunal (FTT) which ruled in favour of the appellants over the closure notices (08/19).

The decision was in turn reversed by the Upper Tribunal in 2021 but was granted a second appeal concerning a total of £1.75m in tax payments.

The appellants are Quentin David Skinner, the settler, and Barnabas Paul Clevely, and involved a claim for entrepreneurs’ relief under the Taxation of Chargeable Gains Act 1992 (TGGA).

Skinner and Clevely had applied for certain disposals of trust of its business assets made by three related family settlements.